Legal Opinion

Stokes v. Commissioner

United States Tax Court

Decided May 27, 1954No. Docket Nos. 30929, 31148, 31657, 33800PublishedCited by 35 opinions

1. Held, that the deficiency notice dated September 15, 1950, relating to 1946, 1947, and 1949, involved in Docket No. 31657, addressed to W. Cleve Stokes and Alice Hill Stokes and which followed a second jeopardy assessment made on or about August 31, 1950, against petitioners was a valid deficiency notice and we have jurisdiction to hear and decide that proceeding. 2. Petitioner W. Cleve Stokes was engaged in the operation of a nursery in 1946, 1947, and part of 1948, and…

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1. Held, that the deficiency notice dated September 15, 1950, relating to 1946, 1947, and 1949, involved in Docket No. 31657, addressed to W. Cleve Stokes and Alice Hill Stokes and which followed a second jeopardy assessment made on or about August 31, 1950, against petitioners was a valid deficiency notice and we have jurisdiction to hear and decide that proceeding. 2. Petitioner W. Cleve Stokes was engaged in the operation of a nursery in 1946, 1947, and part of 1948, and petitioner Alice Hill Stokes was operating the nursery after it was transferred to her November 9, 1948, and throughout…

1Opinion of the Court

OPINION.

Black, Judge:

Some of the major issues originally raised in these proceedings have been settled by stipulation and will be given effect under Bule 50. The remaining questions before the Court are the following: (1) Was it proper for petitioners to deduct the full cost of the nursery plants and shrubs in the year purchased or should those costs be deducted as “cost of goods sold” to the extent of 50 per cent of the sales price as determined by respondent, and (2) to what extent is Alice Hill Stokes liable as a transferee of the assets of W. Cleve Stokes for taxes and penalties for the…

2Cases cited3 opinions

  1. Edson v. LucasCourt of Appeals for the Eighth Circuit · 1930
  2. Rowen v. CommissionerUnited States Tax Court · 1952
  3. Alexander v. CommissionerUnited States Tax Court · 1954

3Cited by35 opinions

  1. Van Raden v. CommissionerUnited States Tax Court · 1979
  2. Packard v. CommissionerUnited States Tax Court · 1985
  3. Gumm v. CommissionerUnited States Tax Court · 1989
  4. John Ownbey Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1981
  5. Powerstein v. CommissionerUnited States Tax Court · 1992

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